HASTINGS DISTRICT COUNCIL AND GENESIS ENERGY
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ELECTRICITY INDUSTRY PARTICIPATION CODE
DISTRIBUTED UNMETERED LOAD AUDIT REPORT
VERITEK
For
HASTINGS DISTRICT COUNCIL AND
GENESIS ENERGY
Prepared by: Steve Woods
Date audit commenced: 13 November 2020
Date audit report completed: 2 December 2020
Audit report due date: 01-Dec-20
1TABLE OF CONTENTS
Executive summary ....................................................................................................................................... 3
Audit summary .............................................................................................................................................. 4
Non-compliances ................................................................................................................................ 4
Recommendations .............................................................................................................................. 5
Issues 5
1. Administrative ..................................................................................................................................... 6
Exemptions from Obligations to Comply with Code ................................................................. 6
Structure of Organisation .......................................................................................................... 6
Persons involved in this audit.................................................................................................... 7
Hardware and Software ............................................................................................................ 7
Breaches or Breach Allegations ................................................................................................. 7
ICP Data ..................................................................................................................................... 7
Authorisation Received ............................................................................................................. 8
Scope of Audit ........................................................................................................................... 8
Summary of previous audit ....................................................................................................... 9
Distributed unmetered load audits (Clause 16A.26 and 17.295F) ............................................ 9
2. DUML database requirements ..........................................................................................................10
Deriving submission information (Clause 11(1) of Schedule 15.3) .........................................10
ICP identifier and items of load (Clause 11(2)(a) and (aa) of Schedule 15.3) .........................11
Location of each item of load (Clause 11(2)(b) of Schedule 15.3) ..........................................11
Description and capacity of load (Clause 11(2)(c) and (d) of Schedule 15.3) .........................12
All load recorded in database (Clause 11(2A) of Schedule 15.3) ............................................12
Tracking of load changes (Clause 11(3) of Schedule 15.3) ......................................................15
Audit trail (Clause 11(4) of Schedule 15.3) ..............................................................................15
3. Accuracy of DUML database .............................................................................................................16
Database accuracy (Clause 15.2 and 15.37B(b)) .....................................................................16
Volume information accuracy (Clause 15.2 and 15.37B(c)) ....................................................18
Conclusion ...................................................................................................................................................21
Participant response .........................................................................................................................22
2EXECUTIVE SUMMARY
This audit of the Hastings District Council (HDC) Unmetered Streetlights DUML database and processes
was conducted at the request of Genesis Energy Limited (Genesis), in accordance with clause 15.37B. The
purpose of this audit is to verify that the volume information is being calculated accurately, and that
profiles have been correctly applied.
The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1.
A RAMM database is managed by HDC and monthly reporting is provided to Genesis. The database is
remotely hosted by RAMM Software Ltd. The field work, asset data capture and database population is
conducted by Pope Electrical.
The audit identified three main issues, as follows:
1. In absolute terms, total annual consumption is estimated to be 73,700 kWh lower than the DUML
database indicates, based on a field audit of 329 items of load.
2. Submission is based on a snapshot of the database at the end of the month and does not consider
historic adjustments, or the fact that lights can be livened before they are entered into the
database.
3. There are incorrect ballast wattages leading to over submission of 11,147 kWh per annum.
The future risk rating of 30 indicates that the next audit be completed in three months. I recommend a
next audit period of six to nine months to allow Genesis time to work through these issues with their
agent.
3AUDIT SUMMARY
NON-COMPLIANCES
Subject Section Clause Non-Compliance Controls Audit Breach Remedial
Risk Risk Action
Rating Rating
Deriving 2.1 11(1) of In absolute terms, total Weak High 9 Identified
submission Schedule annual consumption is
information 15.3 estimated to be 73,700
kWh lower than the
DUML database
indicates.
The monthly database
extract provided does
not track changes at a
daily basis and is
provided as a snapshot.
Incorrect ballasts
applied resulting in an
estimated 11,147 kWh
over submission.
All load 2.5 11(2A) of Three additional lights Weak Low 3 Investigating
recorded in Schedule identified by the field
the database 15.3 count.
Database 3.1 15.2 and In absolute terms, total Weak High 9 Investigating
accuracy 15.37B(b) annual consumption is
estimated to be 73,700
kWh lower than the
DUML database
indicates.
Incorrect ballasts
applied resulting in an
estimated 11,147 kWh
over submission.
4Subject Section Clause Non-Compliance Controls Audit Breach Remedial
Risk Risk Action
Rating Rating
Volume 3.2 15.2 and In absolute terms, total Weak High 9 Investigating
information 15.37B(c) annual consumption is
accuracy estimated to be 73,700
kWh lower than the
DUML database
indicates.
The monthly database
extract provided does
not track changes at a
daily basis and is
provided as a snapshot.
Incorrect ballasts
applied resulting in an
estimated 11,147 kWh
over submission.
Future Risk Rating 30
Future risk 0 1-4 5-8 9-15 16-18 19+
rating
Indicative audit 36 months 24 months 18 months 12 months 6 months 3 months
frequency
RECOMMENDATIONS
Subject Section Description Action
Nil
ISSUES
Subject Section Description Issue
Nil
51. ADMINISTRATIVE
Exemptions from Obligations to Comply with Code
Code reference
Section 11 of Electricity Industry Act 2010.
Code related audit information
Section 11 of the Electricity Industry Act provides for the Electricity Authority to exempt any participant
from compliance with all or any of the clauses.
Audit observation
Section 11 of the Electricity Industry Act provides for the Electricity Authority to exempt any participant
from compliance with all or any of the clauses.
Audit commentary
There are no exemptions in place relevant to the scope of this audit.
Structure of Organisation
Genesis provided the relevant organisational structure:
6Persons involved in this audit
Auditor:
Name Title
Steve Woods Auditor
Other personnel assisting in this audit were:
Name Title Company
Craig Young Excellence Leader - Reconciliation Genesis Energy
Grace Hawken Technical Specialist - Reconciliations Team Genesis Energy
Marius Van Niekerk Transportation Asset Manager Hastings DC
Hardware and Software
The RAMM database used for the management of DUML is remotely hosted by RAMM Software Ltd.
HDC confirmed that the database back-up is in accordance with standard industry procedures. Access to
the database is secure by way of password protection.
Systems used by the trader to calculate submissions are assessed as part of their reconciliation participant
audits.
Breaches or Breach Allegations
There are no breach allegations relevant to the scope of this audit.
ICP Data
ICP Number Description NSP Profile Number of Database wattage
items of (kW)
load
0000939902HBFF4 STREETLIGHTING FHL0331 NST 2593 164.673
MASTER ICP -
FHL0331
0000939904HBE7B STREETLIGHTS - FHL0331 NST 103 10.725
RURAL MASTER
ICP - FHL0331
0000045106HB0D7 STREETLIGHTING RDF0331 NST 21 2.49
MASTER ICP -
RDF0331
70000045104HB052 STREETLIGHTING WTU0330 NST 4558 340.484
MASTER ICP -
WTU0331
0000045107HBC92 STREETLIGHTS - RDF0331 NST 80 4.441
RURAL MASTER
ICP - RDF0331
0000045105HBC17 STREETLIGHTS - WTU0331 NST 54 4.687
RURAL MASTER
ICP - WTU0331
Authorisation Received
All information was provided directly by Genesis or HDC.
Scope of Audit
This audit of the HDC DUML database and processes was conducted at the request of Genesis, in
accordance with clause 15.37B. The purpose of this audit is to verify that the volume information is being
calculated accurately, and that profiles have been correctly applied.
The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1.
The database is remotely hosted by RAMM Software Ltd. The field work, asset data capture and database
population is conducted by Pope Electrical. The database is managed by Beca Limited on behalf of HDC.
The scope of the audit encompasses the collection, security and accuracy of the data, including the
preparation of submission information based on the database reporting. The diagram below shows the
audit boundary for clarity.
Audit Boundary
Pope Electrical HDC
Field work and asset data Database
capture reporting
Beca
Genesis Energy
RAMM Software Ltd
Reconciliation
Database Preparation of submission Manager
management information
RAMM database
8The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1.
The audit was carried out in Hastings on 13/11/20. A field audit was conducted of 329 items of load.
Summary of previous audit
Genesis provided a copy of the last audit report undertaken by Steve Woods of Veritek Limited in May
2019. The table below records the findings.
Table of Non-Compliance
Subject Section Clause Non-compliance Status
Deriving 2.1 11(1) of Incorrect ballasts applied resulting in an Still existing
submission Schedule 15.3 estimated 11,147 kWh over submission.
information
Database 3.1 15.2 and Incorrect ballasts applied resulting in an Still existing
accuracy 15.37B(b) estimated 11,147 kWh over submission.
Volume 3.2 15.2 and Incorrect ballasts applied resulting in an Still existing
information 15.37B(c) estimated 11,147 kWh over submission.
accuracy
Table of Recommendations
Subject Section Clause Recommendation for Improvement Status
Nil
Distributed unmetered load audits (Clause 16A.26 and 17.295F)
Code reference
Clause 16A.26 and 17.295F
Code related audit information
Retailers must ensure that DUML database audits are completed:
1. by 1 June 2018 (for DUML that existed prior to 1 June 2017)
2. within three months of submission to the reconciliation manager (for new DUML)
3. within the timeframe specified by the Authority for DUML that has been audited since 1 June
2017.
Audit observation
Genesis has requested Veritek to undertake this streetlight audit.
Audit commentary
This audit report confirms that the requirement to conduct an audit has been met for this database within
the required timeframe. Compliance is confirmed.
92. DUML DATABASE REQUIREMENTS
Deriving submission information (Clause 11(1) of Schedule 15.3)
Code reference
Clause 11(1) of Schedule 15.3
Code related audit information
The retailer must ensure the:
• DUML database is up to date
• methodology for deriving submission information complies with Schedule 15.5.
Audit observation
The process for calculation of consumption was examined and the application of profiles was checked.
The database was checked for accuracy.
Audit commentary
Genesis reconciles this DUML load using the NST profile.
I checked the submission calculation provided by Genesis and found the correct kW and hours figures
were used.
The field audit found a large number of errors. In absolute terms, total annual consumption is estimated
to be 73,700 kWh lower than the DUML database indicates.
Submission is based on a snapshot of the database at the end of the month and does not consider historic
adjustments, or the fact that lights can be livened before they are entered into the database.
There is some inaccurate data within the database used to calculate submissions as detailed in the table
below. This is recorded as non-compliance and discussed in sections 2.4, 3.1 and 3.2.
Issue Volume information impact (annual kWh)
Incorrect ballasts applied 11,147 kWh over submission
Audit outcome
Non-compliant
Non-compliance Description
Audit Ref: 2.1 In absolute terms, total annual consumption is estimated to be 73,700 kWh lower
than the DUML database indicates.
With: Clause 11(1) of
Schedule 15.3 The monthly database extract provided does not track changes at a daily basis and
is provided as a snapshot.
Incorrect ballasts applied resulting in an estimated 11,147 kWh over submission.
From: 01-Nov-17
Potential impact: High
To: 15-Apr-19
Actual impact: High
Audit history: Three times
Controls: Weak
Breach risk rating: 9
10Audit risk rating Rationale for audit risk rating
High The controls are rated as weak, because they are insufficient to ensure the
database is accurate most of the time.
The impact is assessed to be high, based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis has raised these instances with HDC and will follow up to 01/03/2021 Identified
ensure the correct ballast is applied.
Preventative actions taken to ensure no further issues will occur Completion
date
Genesis has reviewed the October data set provided by the HDC I
November by the database administrator and found what
Genesis believes to be inaccurate gear wattages (9 instances)
annual kWh 265
ICP identifier and items of load (Clause 11(2)(a) and (aa) of Schedule 15.3)
Code reference
Clause 11(2)(a) and (aa) of Schedule 15.3
Code related audit information
The DUML database must contain:
• each ICP identifier for which the retailer is responsible for the DUML
• the items of load associated with the ICP identifier.
Audit observation
The database was checked to confirm the correct ICP was recorded against each item of load.
Audit commentary
All items of load have an ICP recorded against them.
Audit outcome
Compliant
Location of each item of load (Clause 11(2)(b) of Schedule 15.3)
Code reference
Clause 11(2)(b) of Schedule 15.3
Code related audit information
The DUML database must contain the location of each DUML item.
Audit observation
The database was checked to confirm the location is recorded for all items of load.
Audit commentary
11The database contains fields for the street address and also GPS coordinates. There are three records
that do not have GPS coordinates, but in all cases the item of load can be located by the address.
Audit outcome
Compliant
Description and capacity of load (Clause 11(2)(c) and (d) of Schedule 15.3)
Code reference
Clause 11(2)(c) and (d) of Schedule 15.3
Code related audit information
The DUML database must contain:
• a description of load type for each item of load and any assumptions regarding the capacity
• the capacity of each item in watts.
Audit observation
The database was checked to confirm that it contained a field for lamp type, wattage capacity, and
included any ballast or gear wattage. Wattages were checked for alignment with the published
standardised wattage table produced by the Electricity Authority.
Audit commentary
Fields exist in RAMM for lamp make and model. I analysed the database and found no blank records, but
there were several incorrect ballast wattages, as recorded in section 3.1.
Audit outcome
Compliant
All load recorded in database (Clause 11(2A) of Schedule 15.3)
Code reference
Clause 11(2A) of Schedule 15.3
Code related audit information
The retailer must ensure that each item of DUML for which it is responsible is recorded in this database.
Audit observation
The field audit was undertaken of 329 lights using the statistical sampling methodology. The population
was divided into the following strata:
• Amenity,
• Roading A-H,
• Roading I-M,
• Roading N-Z, and
• NZTA.
Audit commentary
The field audit findings are detailed in the table below and show some discrepancies.
12Road SLIM Pole DB watts Field watts Comments
PARK ROAD
SOUTH 0 103 Additional 103W LED
TE AUTE ROAD 0 114 Additional 100W HPS
TE AUTE ROAD 0 114 Additional 100W HPS
FERRY ROAD 79 -
93 33044 83 21 LED estimated at 21 watts
KIRKWOOD ROAD 38851 114 134 134 watt LED installed
KIRKWOOD ROAD 38870 114 134 134 watt LED installed
KIRKWOOD ROAD 39923 114 134 134 watt LED installed
KIRKWOOD ROAD 38944 114 134 134 watt LED installed
KIWI LANE 28 0 Light has been removed
37717
NELSON STREET
SOUTH 36158 153 68 68 watt LED
NELSON STREET
SOUTH 41849 102 75 75 watt LED
NELSON STREET
SOUTH 41847 102 75 75 watt LED
NELSON STREET
SOUTH 36066 168 75 75 watt LED
NELSON STREET
SOUTH 36026 168 75 75 watt LED
NELSON STREET
SOUTH 36021 168 75 75 watt LED
NELSON STREET
SOUTH 35984 168 75 75 watt LED
NELSON STREET
SOUTH 35969 168 75 75 watt LED
NELSON STREET
SOUTH 35933 168 75 75 watt LED
NELSON STREET
SOUTH 35927 278 75 75 watt LED
13NELSON STREET
SOUTH 35867 20 28 28 watt LED
RUAHAPIA ROAD
33105 168 112 LED installed estimated at 112 watts
(NORTH)
SOUTHERN This is a double fitting with two 100 watt HPS. The
35800 114 228
CARPARK database has this recorded as a single fitting
STATE HIGHWAY
36835 168 0 Fitting was not found in the field
51
STATE HIGHWAY
42054 150 112 112 W LED
51
STATE HIGHWAY
42053 150 112 112 W LED
51
The field audit found several discrepancies as recorded in the table above.
This clause relates to lights in the field not recorded in the database. There were three additional lamps
found in the field.
Audit outcome
Non-compliant
Non-compliance Description
Audit Ref: 2.5 Three additional lights identified by the field count.
With: Clause 11(2A) of Potential impact: Medium
Schedule 15.3
Actual impact: Low
Audit history: None
From: 01-Apr-19
Controls: Weak
To: 16-Nov-20
Breach risk rating: 3
Audit risk rating Rationale for audit risk rating
Low The controls are rated as weak, because they are insufficient to ensure the
database is accurate most of the time.
The impact is assessed to be low based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis has requested HDC review the asset database to ensure 01/03/2020 Investigating
all assets are accounted for. Genesis will follow up with the
council monthly to establish whether the database has been
populated with the missing assets found in the field and that the
assets not found are either removed or the correct locational
details are populated.
14Preventative actions taken to ensure no further issues will Completion
occur date
Tracking of load changes (Clause 11(3) of Schedule 15.3)
Code reference
Clause 11(3) of Schedule 15.3
Code related audit information
The DUML database must track additions and removals in a manner that allows the total load (in kW) to
be retrospectively derived for any given day.
Audit observation
The ability of the database to track changes was assessed and the process for tracking of changes in the
database was examined.
Audit commentary
The database functionality achieves compliance with the code.
Audit outcome
Compliant
Audit trail (Clause 11(4) of Schedule 15.3)
Code reference
Clause 11(4) of Schedule 15.3
Code related audit information
The DUML database must incorporate an audit trail of all additions and changes that identify:
• the before and after values for changes
• the date and time of the change or addition
• the person who made the addition or change to the database.
Audit observation
The database was checked for audit trails.
Audit commentary
The database has a complete audit trail.
Audit outcome
Compliant
153. ACCURACY OF DUML DATABASE
Database accuracy (Clause 15.2 and 15.37B(b))
Code reference
Clause 15.2 and 15.37B(b)
Code related audit information
Audit must verify that the information recorded in the retailer's DUML database is complete and
accurate.
Audit observation
The DUML Statistical Sampling Guideline was used to determine the database accuracy. The table below
shows the survey plan.
Plan Item Comments
Area of interest Hastings District Council streetlights
Strata The database contains items of load in the Hastings
District Council area.
The processes for the management of items of load are
the same, but I decided to place the items of load into
five strata, as follows:
• Amenity,
• Roading A-H,
• Roading I-M,
• Roading N-Z, and
• NZTA.
Area units I created a pivot table of the roads in each area and I
used a random number generator in a spreadsheet to
select a total of 38 sub-units.
Total items of load 329 items of load were checked.
Wattages were checked for alignment with the published standardised wattage table produced by the
Electricity Authority.
Audit commentary
Database accuracy based on the field audit
A field audit was conducted of a statistical sample of 329 items of load. The “database auditing tool” was
used to analyse the results, which are shown in the table below.
Result Percentage Comments
The point estimate of R 96.7 Wattage from survey is lower than the database wattage by
3.3%
RL 87.8 With a 95% level of confidence it can be concluded that the
error could be between -12.2% and +1.2%
RH 101.2
16These results were categorised in accordance with the “Distributed Unmetered Load Statistical Sampling
Audit Guideline”, effective from 01/02/19 and the table below shows that Scenario C (detailed below)
applies.
The conclusion from Scenario C is that the variability of the sample results across the strata means that
the true wattage (installed in the field) could be between 12.2% lower and 1.2% higher than the wattage
recorded in the DUML database. Non-compliance is recorded because the potential error is greater than
5.0%.
In absolute terms the installed capacity is estimated to be 17.0 kW lower than the database indicates.
There is a 95% level of confidence that the installed capacity is between 6 kW higher and 64 kW lower
than the database.
In absolute terms, total annual consumption is estimated to be 73,700 kWh lower than the DUML
database indicates.
There is a 95% level of confidence that the annual consumption is between 274,300 kWh p.a. lower to
27,200 kWh p.a. higher than the database indicates.
Scenario Description
A - Good accuracy, good precision This scenario applies if:
(a) RH is less than 1.05; and
(b) RL is greater than 0.95
The conclusion from this scenario is that:
(a) the best available estimate indicates that the
database is accurate within +/- 5 %; and
(b) this is the best outcome.
B - Poor accuracy, demonstrated with statistical This scenario applies if:
significance
(a) the point estimate of R is less than 0.95 or greater
than 1.05
(b) as a result, either RL is less than 0.95 or RH is greater
than 1.05.
There is evidence to support this finding. In statistical
terms, the inaccuracy is statistically significant at the
95% level
C - Poor precision This scenario applies if:
(a) the point estimate of R is between 0.95 and 1.05
(b) RL is less than 0.95 and/or RH is greater than 1.05
The conclusion from this scenario is that the best
available estimate is not precise enough to conclude
that the database is accurate within +/- 5 %
As detailed in section 2.1, incorrect ballasts are applied resulting in an estimated 11,147 kWh over
submission.
17Audit outcome
Non-compliant
Non-compliance Description
Audit Ref: 3.1 In absolute terms, total annual consumption is estimated to be 73,700 kWh lower
than the DUML database indicates.
With: Clause 15.2 and
15.37B(b) Incorrect ballasts applied resulting in an estimated 11,147 kWh over submission.
Potential impact: High
From: 01-Nov-17 Actual impact: High
To: 15-Apr-19 Audit history: Three times
Controls: Weak
Breach risk rating: 9
Audit risk rating Rationale for audit risk rating
High The controls are rated as weak, because they are insufficient to ensure the
database is accurate most of the time.
The impact is assessed to be high, based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis has requested HDC review the asset database to ensure 01/03/2020 Investigating
all asset information is complete and accurate. Genesis will follow
up with the council monthly for exception management.
Preventative actions taken to ensure no further issues will occur Completion
date
Volume information accuracy (Clause 15.2 and 15.37B(c))
Code reference
Clause 15.2 and 15.37B(c)
Code related audit information
The audit must verify that:
• volume information for the DUML is being calculated accurately
• profiles for DUML have been correctly applied.
Audit observation
The submission was checked for accuracy for the month the database extract was supplied. This included:
• checking the registry to confirm that the ICP has the correct profile and submission flag, and
• checking the database extract combined with the burn hours against the submitted figure to
confirm accuracy.
18Audit commentary
Genesis reconciles this DUML load using the NST profile.
I checked the submission calculation provided by Genesis and found the correct kW and hours figures
were used.
The field audit found a large number of errors. In absolute terms, total annual consumption is estimated
to be 73,700 kWh lower than the DUML database indicates.
Submission is based on a snapshot of the database at the end of the month and does not consider historic
adjustments, or the fact that lights can be livened before they are entered into the database.
There is some inaccurate data within the database used to calculate submissions as detailed in the table
below. This is recorded as non-compliance and discussed in sections 2.4, 3.1 and 3.2.
Issue Volume information impact (annual kWh)
Incorrect ballasts applied 11,147 kWh over submission
Audit outcome
Non-compliant
Non-compliance Description
Audit Ref: 3.2 In absolute terms, total annual consumption is estimated to be 73,700 kWh lower
than the DUML database indicates.
With: Clause 15.2 and
15.37B(c) The monthly database extract provided does not track changes at a daily basis and
is provided as a snapshot.
Incorrect ballasts applied resulting in an estimated 11,147 kWh over submission.
From: 01-Apr-19
Potential impact: High
To: 16-Nov-20
Actual impact: High
Audit history: Three times
Controls: Weak
Breach risk rating: 9
Audit risk rating Rationale for audit risk rating
High The controls are rated as weak, because they are insufficient to ensure the
database is accurate most of the time.
The impact is assessed to be high, based on the kWh differences described above.
Actions taken to resolve the issue Completion Remedial action status
date
Genesis has requested HDC review the asset database to ensure 01/03/2020 Investigating
all asset information is complete and accurate. Genesis will follow
up with the council monthly for exception management. Tracking
of changes has been requested by Genesis to be included in the
monthly reporting.
19Preventative actions taken to ensure no further issues will occur Completion
date
Genesis has reviewed data sets and provided feedback to the
database administrator outlining the importance of change
tracking. Genesis will need to work further with the council’s
contractor find the solution to this non-compliance.
20CONCLUSION
The audit was conducted in accordance with the audit guidelines for DUML audits version 1.1.
A RAMM database is managed by HDC and monthly reporting is provided to Genesis. The database is
remotely hosted by RAMM Software Ltd. The field work, asset data capture and database population is
conducted by Pope Electrical.
The audit identified three main issues, as follows:
1. In absolute terms, total annual consumption is estimated to be 73,700 kWh lower than the DUML
database indicates, based on a field audit of 329 items of load.
2. Submission is based on a snapshot of the database at the end of the month and does not consider
historic adjustments, or the fact that lights can be livened before they are entered into the
database.
3. There are incorrect ballast wattages leading to over submission of 11,147 kWh per annum.
The future risk rating of 30 indicates that the next audit be completed in three months. I recommend a
next audit period of six to nine months to allow Genesis time to work through these issues with their
agent.
21PARTICIPANT RESPONSE
Genesis has requested the council to review its asset information and to find a solution enabling the
tracking of change information to be reporting monthly to the trader.
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